Electric Elans, ANY EV classic, or anything with a 'hole'

[Bitsilly]

Hi all,
Some of you will know of my current problems of my Mini being permanently taken off the road because I drilled holes in the boot as part of the electrification.
This new application of the DVLA rules, if extrapolated or not, will cause all sorts of problems for classic car owners, not just electric ones.
I have drafted a letter, which is long but says it all.
If anyone out there knows any motoring journalists, editors, civil servants etc etc please could you forward the letter on to them. Alternatively let me know and I will forward it.
A relevant selection of photos is also available, which can be sent to any e-mail address you want, anything else is currently beyond my ICT ability!
Sorry to be a drag, but I really think this idiocy should be reported and addressed.
Writing the letter was very cathartic, which I really needed!!
Please feel free to change it as you see fit, although my wife told me dripping sarcasm, crude expletives and personal insults are not allowed (even when totally justified!).
Cheers in advance.
Ed
(also posted on the Mini forum)
the letter:


Dear .......

I apologise for any intrusion, but I feel it important to inform interested parties of the implications of a recent change the DVLA has made to its interpretation of government policy.

The change will bring an abrupt halt to the growing industry of converting classic cars to electric power simply because if any hole is drilled as part of the conversion, then an IVA test will be required.

Additionally, once an attempt at electrification is made and the DVLA is informed, they will confiscate the existing V5, delete the car's Vin number from its data base, and, through insisting on an IVA test, cause the death of many classic cars.

They have also decided that reversal of such works and/or the cancellation of any application is no longer allowed.

I refer to a recent case of the electrification of a 1960 mk1 classic Mini, (their ref. 96628439 Davieslg Kits D9) which seems to have been a test case for their policy change.
Photos can be forwarded if you wish.

This conversion was done with the collaboration of a leading specialist firm's MD, a Doctor of Engineering who developed the electric Transit van for Ford, and by myself, a retired automotive engineer and current car restorer. We like to consider it a far cry from a teenager fitting a flip front and a Vtech engine to a classic mini, or perhaps a motorbike engine in the back seat or a custom rear cradle, all of which have previously been approved by the DVLA.


The entire ethos of the project was to keep the conversion 100% reversible, and to demonstrate what can be done even within such a restraint.


Previous to this case, following an electrification, it had been sufficient to submit the V5 to the DVLA with the 'change of engine' section filled out.

This was done, but instead of a new V5, we recieved a lengthy questionaire asking things such as 'what is the new electric motors cubic capacity'.

When it was pointed out that these questions were unanswerable, the DVLA decided that now, in such cases, they should be applying the rules of their 'Kit cars and Rebuilds' department.

An inspection was arranged, and the greatly impressed but rather confused inspector insisted that there would be no issue in retaining the car's identification.

The DVLA office based staff did not agree with the inspector's opinion and concluded that the previous registration is now invalid and that its identity must be voided. They stated that, "The car requires an IVA and if successful will then be issued a Q-plate".


The reason given for this was that a hole had been cut in the monocoque, in the boot lid behind the hinged number plate.


Following a request for clarification when we pointed out that the boot lid was not part of the 'monocoque', they conceded this point, but now said the problem was that holes had been drilled in the boot.

We offered to weld up the holes, but this was not acceptable as they said nothing can reverse such a 'radical modification' like drilled holes. Reversal, however it is done, will not reverse their decision. An IVA test is needed.

Unfortunately, it is not possible for a classic Mini, nor most other classic cars to pass an IVA test due to their design and manufacture, and the complex nature of the test. An IVA was intended as a tool to judge a modern kit car with a design focussed on passing the test, not to judge a car designed in 1959 and built in 1960.

The Mini, for example, has external welded seams, exposed trim and steering column and edges consided 'sharp' throughout. The major, costly and radical modifications, even if possible, would still be a waste as the design would simply fail on too many other points, and also because its failing features can only be changed by 'methods currently used by mainstream car manufacturers'.

The irony, that because they find unacceptable the incredibly minor modification of a drilled hole, that they must insist on many more radical and serious modifications is curiously lost on the DVLA.

Additionally ironic is that in their own rules as published on the .gov site, in for example "converting a 'box van' to a 'camper van'", an IVA, is not usually required, but the conversion must include modifications like at least two windows being cut, and ideally the roof removed to fit an concertina type roof, so as to ensure the vehicle resembles its new (un-tested and un-inspected) description.

So this is where the case has currently concluded. The car has no legal future other than to be scrapped for parts, although even this is difficult as one is obliged to surrender the V5 to the ATF (Authorised Treatment Facility) while retaining the yellow section. Difficult when they have refused to give it back.


We would greatly appreciate any assistance you can offer to help the DVLA see how it can apply their rules in a more realistic manner as quickly as possible, to prevent more cases like this, and to prevent them choosing to extrapolate on this change of policy and insist that other electric classics or classics with holes, drilled, caused by rust, or otherwise, must now have an IVA test.


We would like the DVLA to adopt the common wisdom that:

* to safely electrify a classic car it is reasonable and necessary to require safely drilled holes.

* that welding is an ongoing requirement for keeping classic cars road worthy, so should be allowed as a way of reversing drilled holes.

* that where one drills holes is admittedly very important, but that a Doctor of Engineering would possibly know better than office administrators on where and how this can be done safely.

* that when an appropriately qualified experienced automotive engineer, intends to make any change to a classic car 100% reversible, that they are capable of and able to ensure that this is the case.

* that drilling a hole in a car's boot should not be described as a 'Radical Modification'.

* that if an application fails the application can be withdrawn on the condition of an inspection to prove originality.


If you agree that their current policy is a mistake, any assistance or advice that you can offer to help appeal or reverse the death of this Mini would be appreciated.

If it is not deemed a mistake then I am afraid that the future of electrification of classic cars and classics with very minor modifications, is at serious risk.

Even if you cannot help, please pass on this information to stop anyone else becoming an out of pocket victim.


Please just ask if you would like any further information, photographs, or copies of the correspondance with the DVLA.

I am happy for any publication or journalist to contact me directly should they need any further references or details​

Many thanks for your attention to this report.

Kind regards

Ed Keane BSc BEng


PS. I would love to say I have exaggerated the simplicity of the problem or that common sense will prevail, but this case has already been ‘elevated’ within the DVLA. The department of transport , the All Party Parliamentary Group on Historic Vehicles, Trudy Harrison, and other MP's have been informed but as yet have not responded.

[richardcox_lotus]

I suggest you also send this to the Times, Guardian and Telegraph and see if that helps raise the profile

Regards,
Richard

[rgh0]

Just send it to everyone every where, politicians from all parties, media, radio, TV news and current affairs, newspapers, car clubs, twitter, Facebook, if you can think of it send it.

There is nothing that scares faceless bureaucrats more than day light

cheers
Rohan

[Slowtus]

"When it was pointed out that these questions were unanswerable..."

That's (part of) the issue right there, some authorities are content with an answer which may be meaningless but does tick a box, job done.

Then you have the nitpicker in chief who delights in flexing his government issued muscles and who seizes such an opportunity.

With glee.

All you can do is try to wear them down and attack from all sides.

[elanfan1]

If you can attract 100,000 signatures you can force a discussion in parliament. Sounds like that might be the answer.

[Elan 1600]

No automobile needs any sort of government check if it is not being used commercially.

[richardcox_lotus]

No automobile needs any sort of government check if it is not being used commercially.

Errr…. I presume you are ignoring an MOT then.

Regards
Richard

[SENC]

Wow, what a charlie-foxtrot! I'm sorry there isn't some way to assist from this side of the pond, but agree with your efforts completely. Also agree with Rohan's observation about politicians. Good luck!

[2cams70]

I won't make any comment regarding the holes drilled because I don't know the full story however an "Individual Vehicle Assessment" is probably not an unreasonable request given the extent of modifications required to replace an ICE powertrain with an electric one. This is just standard practice for any vehicle extensively modified.

Are you sure your vehicle would not pass such a test?

[Bitsilly]

Full story on first post.
They could find absolutely no issue with the electrification.
A car must be designed to pass an IVA, old cars will absolutely not, if anyone tried the result would be an abortion and look nothing like an old car, even that is overlooking the fundamental design issues like set belt mount in the chassis. If you check out some rules you will understand.
It is the holes that are the unacceptable modification, and I would withdraw the application and weld them up if I could but they will not let me.

[Spyder fan]

I feel that your application to the DVLA has been misapplied. The electrification should come under the rules that apply to "radically altered vehicles"

Radically altered vehicles are vehicles that have been altered from their original specification, but are not kit conversions.

https://www.gov.uk/vehicle-registration ... d-vehicles

I would guess that your conversion easily has 8 points?

[SimonH]

I feel that your application to the DVLA has been misapplied. The electrification should come under the rules that apply to "radically altered vehicles"

Radically altered vehicles are vehicles that have been altered from their original specification, but are not kit conversions.

https://www.gov.uk/vehicle-registration ... d-vehicles

I would guess that your conversion easily has 8 points?

I think that’s the issue they’ve decided it has a modified monocoque so can’t have the 5 points from that. If it was all mounted to the subframes and used only original holes it would have been ok. It can’t get the points for original engine or transmission either.
Tbh I’m not sure how the drilling holes would have come into the discussion with them unless they asked if any extra holes had been made.

[Bitsilly]

The car was inspected and the inspector saw how I had mounted things and even said those holes are strictly a modification!!! But he honestly said when I asked if that is a problem "of corse not, I am the representative of the DVLA, if I say everything is fine then it is and I say everything is fine."

And yes even then it should get full points less 1 for the engine, they argued that the chassis is so modified that it cannot ANY points out of 5.

An important point though, when I started this EV conversions just needed to be flagged to the DVLA as an engine change (that's all mine is except for some holes).
Now cases are being referred to Kitcars dept.


Now, lets take a step back, looking beyond what they are allowed to enforce, should they use leeway and sense, or stick to the only issue they found, drilled holes, and rightfully use that to kill a classic, sealing its fate by not allowing it to be reversed.
.

[2cams70]

I’m certainly no expert on what happens in the UK but here the inspectors are just individuals contracted by the registration authorities. It might be worth your while finding another inspector as they may not notice it or have an entirely different opinion and let it through.

[Bitsilly]

Yep, that’s what happened.
I have the Mk1 mini club experts who followed the build closely ready to give a report but they aren’t interested.